Euris Jose Echenique-Duran, a Venezuelan national detained at the North Lake Processing Center in Baldwin, Michigan, challenged his detention by ICE after being arrested at work on March 1, 2026. Echenique-Duran had initially entered the U.S. without inspection near Eagle Pass, Texas, in October 2023, but was released on his own recognizance by DHS and later filed an asylum application before ICE re-arrested him.
Judge Jarbou concluded that Section 1226(a), rather than the mandatory detention provision in Section 1225(b)(2)(A), governs noncitizens like Echenique-Duran who have resided in the United States and were already present when apprehended. The judge further ruled that "Petitioner's current detention under the mandatory detention framework set forth in § 1225(b)(2)(A) violates Petitioner's Fifth Amendment due process rights," citing her constitutional analysis from several similar recent cases in the Western District of Michigan.
The case followed a swift procedural timeline, with Judge Jarbou issuing a show cause order on March 12, 2026, requiring the government to justify the detention within three business days. Respondents filed their response on March 17, arguing that Echenique-Duran should exhaust administrative remedies through a bond hearing and potential appeal to the Board of Immigration Appeals. However, the court declined to enforce the exhaustion doctrine and proceeded to the merits.
The ruling is part of a pattern of similar decisions by Judge Jarbou in the Western District of Michigan, as she cited four other recent cases with virtually identical holdings. The court ordered ICE to provide a bond hearing under Section 1226(a) within five business days or immediately release Echenique-Duran, and to file a status report within six business days certifying compliance with the order.